Procedural Posture
Plaintiff landowner appealed an order of the Superior Court of Imperial County (California), which entered judgment for defendant employee of the landowner and denied the landowner's motion for new trial. The landowner had brought an action to recover property, which he alleged the employee had taken.

Overview
The landowner was in possession of a piece of land upon which he had grown a crop of milo maize. He had entered into an oral agreement with the employee for the employee to perform the labor in cultivating and bringing the crop to maturity. The employee alleged that according to the parties' agreement, he was to receive $ 500 and one-fourth of the crop. Upon quitting the job, the employee, without the landowner's knowledge or consent, hauled away 500 sacks of grain from the landowner's property. The landowner brought an action to recover the grain. The case was tried before a jury, which rendered a verdict in the employee's favor. The trial court denied the landowner's motion for new trial and entered judgment for the employee. The court on appeal reversed the trial court's judgment. The court held that the contract between the parties was one of employment and did not transfer the right of possession of the grain from the landowner to the employee. The court held that the employee's remedy was an action for breach of contract, and his taking of the grain was wrongful.

Outcome: difference between partnership and joint venture
The court reversed the trial court's order denying the landowner a new trial and entering judgment for the employee in the landowner's action to recover property taken by the employee.

Procedural Posture
Defendant corporation petitioned the court for certification following a judgment by the Municipal Court of Malibu Judicial District of Los Angeles County (California), in favor of plaintiff landlord in plaintiff's breach of contract action.

Overview
An officer of defendant corporation signed a lease agreement for a beach house on behalf of defendant in his capacity as president. Plaintiff landlord instituted an action for breach of contract after the officer fell in arrears on rent. At trial, judgment was entered for plaintiff and the appellate court affirmed. Defendant then petitioned for certification to the court pursuant to Cal. R. Ct. 63, to settle an important question of law as to whether the signature of a corporate president, standing alone, was sufficient to bind a corporation pursuant to Cal. Corp. Code § 313. The court held that § 313 required two signatures to bind a corporation. The court noted that the requirement of two signatures enabled third parties to rely upon the assertive authority of corporate officers and also protected corporations from a single rogue officer. Thus, the court reversed and held that the officer's signature was inadequate to bind defendant, and ordered that the matter be remanded for further proceedings.

Outcome
The court reversed and remanded the judgment in favor of plaintiff landlord in plaintiff's suit on a breach of contract on a lease agreement with defendant corporation because defendant was not bound by the signature of a single officer, as the pertinent state statute required the signature of two officers to bind the corporation.